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shorebreak - 4:58 am on Jan 25, 2011 (gmt 0)
The testing and optimization that lead to this change was referred to in Google's latest earnings call with analysts, wherein a Google exec said this was on of two primary drivers of their 'beat the Street' quarter (the other was Ad SiteLinks).
If there was something lower than lower case, and Google's testing showed it made for higher CTR & revenues, they would use it.
-Shorebreak
ooops, sorry, i meant shorebreak